The court discusses questions relating to the general approach taken by the Convention to the grounds for refusal of recognition and enforcement, including its pro-enforcement bias, as well as the system of the Convention, under which recognition and enforcement may only be denied on seven listed grounds and the petitioner has only the obligations set out in Art. IV.

The court discusses the burden of proof of the grounds for refusing enforcement under the Convention.

Award not binding, suspended or set aside: The court discusses the meaning of an award having been “suspended” in the country of origin, including when the award has been suspended by operation of law rather than by a court decision.